Our Privacy Policy
FriendsFlashback Inc. ('FriendsFlashback' or 'we' or 'us') is committed to protecting your privacy. We created this Privacy Policy ('Privacy Policy') to give you confidence as you visit the www.FriendsFlashback.com website located within the FriendsFlashback.com domain ('Site') and use the FriendsFlashback services (the 'Services') provided through the FriendsFlashback Facebook application using Facebook login (the “Application”) and the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. Your use of the Site and the Services is governed by this Privacy Policy and the Terms of Use.
Privacy Policy Simplified
It's important that we make it very clear how your privacy is important to us. To that end, we would like you to review our Privacy Policy and Terms & Conditions, in non-legalese.
We recognize that FriendsFlashback might have access to a lot of your data if you have a large number of services connected. Please know that we do not permanently store your data from these services - we grab your data (photos and posts) to make your flashback work, and then we delete it. We only keep data as long as you wish us to keep us your data to use our services. We strongly request you contact us to delete your data if you wish to do so, because we do not wish to store this data for processing. Your data will be deleteted within 24 hours after submission of this request. Local photos from your computer and mobile device are never uploaded or stored for any reason, they stay private to you.
In order to create your flashback page for Facebook, we sort your Facebook photos and posts to find content that was posted for a specific day or month, and show them on your flashback page. We also give you the option to share a specific memory with your friends by using the Facebook Share button.
FriendsFlashback does not sell your data. We do not share your name or email or other profile data with anyone.
We won’t send you marketing emails if you don’t want us to. This is optional, changeable at any time, by unsubscribing or visiting the Email Notifications tab in the Settings page.
FriendsFlashback is powered by advertising, it's what keeps the app free and the company able to keep building. For this, we only share the approximate location of the user.
Users can contact us at any time via our contact form or emailing us at support@friendsflashback.com. If you wish to close your account, please click on this link to delete your account. When you delete your account, all of the data FriendsFlashback has that belongs to you will be deleted.
We hope this sheds light on how we treat your privacy and data here at FriendsFlashback, and as always will update this with any information that changes.
Table of Contents
About This Privacy Policy and Our Services
Information We Automatically Collect About You
How We Collect, Use, and Disclose Personal Information From Users Who Log Into Our Application
Grounds for Using Your Personal Information
Opt-in / Opt-out
Information Security
Access and Retention of Information
Conditions Of Use
For EEA Residents: Privacy Shield Notice for Personal Data Transfers to the United States
Rights of California Residents
Changes to This Privacy Policy
Contact Information
1. About This Privacy Policy and Our Services
This Privacy Policy is only applicable to the Services and the Site and not to any other applications or websites that you may be able to access from the Services or the Site (whether through an advertisement, service, or content link) or any application or website of FriendsFlashback's partners, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.
While you may use some of the functionality of FriendsFlashback without registration, much of the content on the Site and the Services require registration by logging into the Application. If you use our Site without logging into the Application, the only information we collect will be through the use of Cookies or Web Beacons (please see Section 2). If you choose to log into the Application, we require you to submit certain Personal Information, which is information that personally identifies you (please see Section 3). You are responsible for ensuring the accuracy of the Personal Information you submit to FriendsFlashback. Inaccurate information will affect the information you receive when using our Site and the Services and our ability to contact you as described in this Privacy Policy.
2. Information We Automatically Collect About You
Even if you do not log into the Application, we collect certain information about your use of our Site and Services. FriendsFlashback collects information about devices accessing the Services, including type of device, which operating system is used, device settings, application IDs, and unique device identifiers.
A. Cookies
We use 'cookies' to customize your experience on the Site. 'Cookies' are small computer files that are transferred to your computer's hard drive that contain information such as your user ID, user preferences, the pages you've visited and the activities you've performed while using the Site and Services. We do not link the information stored in cookies to any of your Personal Information you submit while using the Services. You may block cookies or delete cookies from your hard drive; however, by disabling cookies, you may not have access to all of the features of the Site. Some of our business partners also use cookies to provide us with anonymous data and information regarding your use of the Site and Services. We do not have access or control over these cookies, our privacy policy does not cover the use of third party cookies.
B. Web Beacons
We or our third party tracking utility company also use 'web beacons' to collect anonymous information about your use of our Site and Services and the websites of selected sponsors and advertisers, and your use of emails, special promotions or newsletters we send to you. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user's browser. The information collected by web beacons allows us to statistically monitor how many people are using our Site and Services and selected sponsors' and advertisers' sites and opening our emails, and for what purposes. Our web beacons are not used to track your activity outside of our Site or Services or those of our sponsors'. We do not link information from web beacons to Personal Information you have submitted without your permission.
C. Traffic Data
We automatically track and collect the following categories of information when you visit our Site or use our Services: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring source which may have sent you to the Site; and (6) other information associated with the interaction of your browser and the Site (collectively 'Traffic Data'). We do not link Traffic Data to other information we have collected from you Information without your permission.
3. How We Collect, Use, and Disclose Personal Information From Users Who Log Into Our Application
This Section of the Privacy Policy describes how we collect, use, and disclose your Personal Information. In the past twelve months (from the effective date of this version of the Privacy Policy) we have collected the categories of information listed in this section. We have shared or sold information in the past twelve months only as specified below. California residents and European Economic Area (“EEA”) residents have certain rights regarding our collection, use, and disclosure of Personal Information. California residents should view Section 10 of this Privacy Policy to learn about their rights, and EEA residents should view Section 9.
A. Collection of Personal Information
In order for you to access certain areas of the Site and for you to use the Service, we require you to provide us with certain Personal Information. Personal Information that you provide to us may include, without limitation:
Identifiers, such as your first and last name, email address, IP address, date of birth, phone number, and usernames for third party social networking and other services where you have contributed content to which you grant FriendsFlashback access.
Geolocation information, such as your time zone and physical location.
Your age and gender, which are protected characteristics.
Content you have contributed to third party social networking and other services. Your content may include various types of Personal Information, including photos of yourself, depending on what you share on social networking sites and other services. You may provide us with your content from services including but not limited to Twitter, Facebook, Swarm, Instagram, YouTube, Tumblr, Dropbox, Google, Photo Gallery, Camera Roll, and SMS/text messaging services.
Internet activity information, such as information regarding your use of our Service, and browser information.
We may require you to create a password to use the Application.
B. Use of Personal Information
We use the Personal Information that you provide to respond to your questions, provide you the specific services you select and send you emails about Site and Services maintenance and updates. We may use your contact data to send you information about FriendsFlashback or our products or Services, to contact you when necessary and in conjunction with your use of certain Services. We may use your Traffic Data to customize and tailor your experience on the Site and Services, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. You may choose not to provide us with any Personal Information. In such case, you can still access the Site; however, you will not be able to access and use those portions of the Site that require your Personal Information or be able to use our Services. Additionally:
i. Inquiries
Subject to the Privacy Policy, if you contact FriendsFlashback, we may use any of the information you submit in connection with your inquiry, or any other information we have collected from you when responding to your inquiries.
ii. Email to You
We may use your contact data to send you information to contact you when necessary, including registration verification emails, and in conjunction with your use of the Services, including e-mails containing content from third party sites and services which you have permitted FriendsFlashback to access.
iii. Market Research
From time to time the FriendsFlashback market research department, or its operations contractors acting on its behalf, may conduct online research in order to gather feedback about our Site and our sponsors through email invitations, pop-up surveys and online focus groups. When participating in a survey, we may ask you to submit Personal Information. This Personal Information is used for research purposes, and is not used for sales solicitations. When a survey is sponsored by a third party, aggregate information of the survey results is reported to the sponsor. Personal Information collected through market research will be used only by FriendsFlashback and its service providers and contractors and will not be given or sold to third parties other than such service providers or contractors without your consent or as otherwise permitted by this Privacy Policy. We will not knowingly accept survey responses from or conduct interviews with any person under the age of 18. In addition to collecting survey responses from our members, cookies may be used to authenticate respondents or to help you pick up where you left off in a survey. If you have cookies disabled you may not be able to participate in some studies. Cookies may be used to connect survey data with FriendsFlashback site usage characteristics. You will be notified when we would like to use cookies in this way and your consent will be requested for these cookies.
C. Disclosure of Personal Information
We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Personal Information and Traffic Data with other companies and people who assist us by performing core services (such as website hosting, data storage and security, marketing assistance and customer service) related to our operation of the Site and/or by making certain Services available to our users. Those business partners and agents shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to and to provide you with Site related services. FriendsFlashback may share aggregated demographic information with business partners, and anonymized information with analytics and advertising partners.
FriendsFlashback’s accountability for personal data that it receives in the United States under the EU-US Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, FriendsFlashback remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless FriendsFlashback proves that it is not responsible for the event giving rise to the damage.
We may transfer information about you to another company in connection with a merger, sale of assets or the business or acquisition by or of FriendsFlashback. If FriendsFlashback, or substantially all of its assets were acquired, or in the unlikely event that FriendsFlashback goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of FriendsFlashback may continue to use your Personal Information as set forth in this policy.
FriendsFlashback does not share, sell, rent or trade your Personal Information with any third parties for their promotional purposes, other than making Personal Information available to advertising networks.
We reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights, the rights of any third party and/or comply with a judicial proceeding, court order, or legal process served on our Site or Services, or in urgent circumstances to protect the personal safety of users of our Services or members of the public. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
i. Information Collected by Third Parties Not Acting on Behalf of FriendsFlashback
Certain content and Services offered to you through our Site and Application are served on websites hosted and operated by a company other than FriendsFlashback ("Third Party Contractor Websites"). FriendsFlashback does not disclose information collected from you to these Third Party Contractor Websites, other than unique device identifiers and information disclosed with your explicit consent, but you should be aware that any information you disclose once you access these other websites is not subject to this Privacy Policy. FriendsFlashback does not endorse and is not responsible for the privacy practices of these Third Party Contractor Websites. You should review the privacy policy posted on any other website to understand how that Third Party Contractor Website collects and uses your personally identifiable information.
ii. Third Party Websites
The Site may contain links to third party websites to which FriendsFlashback has no affiliation. FriendsFlashback does not share your personal information with those websites and is not responsible for their privacy practices. Some websites may have the look and feel of our Site. Please be aware that this Privacy Policy only covers our Site. Should you decide to visit third party websites, we suggest that you read their privacy policies.
If you register for the Service and grant FriendsFlashback access to accounts you may have with third party service providers, Personal Information that you post to your accounts with those third party service providers may be viewable on or through the Site and Services, subject to the privacy settings you have set in your third party accounts.
4. Grounds for Using Your Personal Information
We rely on the following legal grounds to process your Personal Information, namely:
Performance of a contract – When you log into our Application, we need to collect and use some of your Personal Information to perform our agreement with you to deliver the Services in accordance with our Terms of Service and this Privacy Policy.
Consent – We may also collect, use or disclose some additional Personal Information as described in this Privacy Policy subject to your consent.
Legitimate interests – Finally, we may use your Personal Information for our legitimate interests to provide and improve our Services. To create your personal daily time capsule and deliver it to you each day through our Application, we need to access and use your Personal Information. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.
5. Opt-in / Opt-out
A. Marketing Opt-in
When you register for our Services, if your location indicates you are an EEA resident, we will request that you to opt-in, i.e. click a button, to receive our Services. We will further request that you check a box if you agree that we may use your e-mail address to send marketing messages to you. If you do not check that box, you will not receive our marketing messages. If you checked the box to agree but you no longer wish to receive emails from us, you may opt-out of receiving them by following the instructions included in each email, or by emailing us at support@friendsflashback.com. You may also contact us as described in Section 12 below. If you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Site and Services.
We will provide you with an opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our business partners or agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@friendsflashback.com.
B. INTEREST-BASED ADVERTISING IN THE APPLICATION
To opt out of interest-based advertising in the Application, follow these instructions:
iPhone/iOS: To “Limit Ad Tracking” on the iOS, please visit
https://itunes.apple.com/us/app/FriendsFlashback-memories-then-now/id569077959?mt=8 or see the instructions below:
Go to “Settings” > “Privacy” > “Advertising.”
Turn on “Limit Ad Tracking.”
Android: To opt out of interest-based ads in the Android OS, please visit privacy
https://play.google.com/store/apps/details?id=com.FriendsFlashback or see the instructions below:
Open Google settings on your device (may be an app called Google Settings or an entry in your phone’s Settings menu, depending on your device)
Tap “Ads”
Switch on “Opt out of interest-based ads” or “Opt out of Ads Personalization.”
C. CROSS-DEVICE TARGETING
FriendsFlashback and our ad partners may combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers and on each of your mobile devices. You must opt out separately on each of your browsers and each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.
D. USE OF LOCATION
To disable the collection of approximate location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.
Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you can uninstall the relevant program(s).
iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.
6. Information Security
FriendsFlashback maintains appropriate technical, security and organizational measures to protect your Personal Information against unauthorized or unlawful processing and use, and against theft or disclosure. Your FriendsFlashback account information is protected by a password for your privacy and security. We use industry-standard Secure Socket Layer (SSL) software to protect the security of your Personal Information during transmission, which encrypts all of the information you input. Only employees or agents who need personal information to perform a specific job are granted access to it. All of our employees are kept up to date on our privacy and security practices. While FriendsFlashback uses commercially reasonable means to secure your information, we do not guarantee that your personal information will not be improperly accessed, disclosed, or destroyed by breach of any of our safeguards.
7. Access and Retention of Information
Pursuant to the Privacy Shield Frameworks, EEA residents have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to support@friendsflashback.com. If requested to remove data, we will respond within a reasonable timeframe.
You may delete your FriendsFlashback account by following the deletion process set forth on the Application. Some information may remain in our records after deletion of your account.
FriendsFlashback will retain your information in accordance with your instructions, as necessary to fulfill the purposes for which it was collected, and as required by applicable law. Certain information, such as photographs and associated metadata collected from your social media accounts is automatically deleted by FriendsFlashback. FriendsFlashback may retain your Information after you have deactivated your account for the period of time needed for FriendsFlashback to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
8. Conditions Of Use
Your use of the Site and Services and any possible dispute over privacy are subject to this Privacy Policy and our Terms and Conditions, including limitations on damages, arbitration of disputes, and application of US law.
9. For EEA Residents: Privacy Shield Notice for Personal Data Transfers to the United States.
FriendsFlashback complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to the Privacy Shield. FriendsFlashback has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, FriendsFlashback is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
In compliance with the Privacy Shield Principles, FriendsFlashback commits to resolve complaints about our collection or use of your personal information. EEA residents with inquiries or complaints regarding our Privacy Shield policy should first contact FriendsFlashback at:
FriendsFlashback has further committed to refer unresolved Privacy Shield complaints to the BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the Better Business Bureau or visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of the Better Business Bureau are provided at no cost to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
If you are a resident of the European Union, you have the right to:
request an accounting of all personal information that we possess that pertains to you in an electronically portable format.
request that we change any personal information that pertains to you.
request that we restrict or delete any personal information that pertains to you.
fully or partially withdraw your consent to the collection, processing, and/or transfer of your personal information. To withdraw your consent, please contact support@friendsflashback.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In case we processed your Personal Information for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Information for such marketing purposes.
You also have a right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
10. Rights of California Residents
California residents have certain rights regarding our collection, use, and disclosure of Personal Information under the California Consumer Privacy Act (“CCPA” or the “Act”). To learn how FriendsFlashback collects, uses, and discloses Personal Information, see Section 03 of this Privacy Policy. For purposes of this “Rights of California Residents” section, the term “Personal Information” means Personal Information under Cal. Civ. Code 1798.140(o). To the extent that any other provision of this Privacy Policy conflicts a provision of this section, the provision in this section controls as to California residents.
If you are a California resident, you may:
Request that we delete your Personal Information (a “Right to Delete Request”).
Opt-out of the sale of your Personal Information (a “Right to Opt-Out Request”).
Request information about our collection, use, and disclosure of your information (a “Right to Know Request”), including:
the categories and specific pieces of Personal Information we have collected about you;
the categories of sources from which we have collected your Personal Information;
the business or commercial purpose for collecting or selling your Personal Information;
the categories of Personal Information we have sold about you; and
the categories of third parties with whom we have shared, disclosed for a business purpose, or sold your Personal Information, and which categories of Personal Information we have sold to which categories of third parties.
We will not discriminate against you for exercising your rights under the CCPA. Consistent with Section 1798.125 of the Act, we may charge users different prices, or provide different levels or quality of goods or services, if the difference is reasonably related to the value of their data.
A. “RIGHT TO KNOW” REQUESTS
California residents may submit a Right to Know Request through Settings in the Application or by emailing FriendsFlashback at support@friendsflashback.com. California residents may submit two types of Right to Know Requests: (1) A Request for the specific pieces of information that FriendsFlashback has collected about you in the past twelve months; or (2) a Request for the categories of Personal Information that FriendsFlashback has collected about you in the past twelve months, and how FriendsFlashback has used and disclose that information. When you submit a Right to Know Request, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. We may also use a third-party identity verification service to attempt to verify your identity.
If FriendsFlashback is able to verify your identity, we will respond to your Right to Know Request by: (a) providing the requested information; or (b) explaining why the Act does not require us to provide the requested information. If FriendsFlashback is unable to verify your identity, FriendsFlashback will respond by explaining why it cannot verify your identity.
We will confirm receipt of your Right to Know Request within 10 days and will respond to your Request within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days. If the Act requires us to provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request or series of Requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s), or may refuse to process the Request(s).
B. “RIGHT TO OPT-OUT” REQUESTS
California residents may opt out of the sale of some or all of their Personal Information by clicking the “Do Not Sell My Personal Information” link located in Settings in our Application or by emailing FriendsFlashback at support@friendsflashback.com. You may be required to provide certain information to verify your identity. We will only use that information for purposes of processing the Request.
Within 15 days of receiving a Right to Opt-Out Request, we will:
Not sell your Personal Information unless and until you subsequently provide express authorization for the sale of your Personal Information.
Notify all third parties to whom we have sold your Personal Information within 90 days prior to our receipt of your Request that you have exercised your Right to Opt-Out, and instruct them not to further sell your Personal Information.
Not ask for permission to sell your Personal Information for 12 months after receiving the Request.
California residents who have opted out of the sale of their Personal Information may opt back into the sale of their Personal Information in Settings in the Application or by emailing support@friendsflashback.com.
C. “RIGHT TO DELETE” REQUESTS
California residents may submit a Right to Delete Request in Settings in the Application or by emailing support@friendsflashback.com. You may request that we delete all or some of your Personal Information.
When you submit a Right to Delete Request, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If FriendsFlashback is able to verify your identity, we will respond to your Request by (a) deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information; or (b) explaining why the Act does not require us to delete your Personal Information. FriendsFlashback may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information. We will specify the manner in which we delete your Personal Information.
If a Request or series of Requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s), or may refuse to process the Request(s).
D. AUTHORIZED AGENTS
California residents may submit Right to Know, Right to Opt-Out, and Right to Delete Requests through an authorized agent. Unless the agent provides FriendsFlashback with a power of attorney executed by the California resident, FriendsFlashback may require the California resident to verify their identity with FriendsFlashback and/or to provide FriendsFlashback with written confirmation of the agent’s authority to make the request.
E. MINORS
FriendsFlashback’s Services, Site and Application are not designed to be used by minors under 16 years of age. FriendsFlashback does not have actual knowledge that it collects or maintains the personal information of minors under 16 years of age. FriendsFlashback does not knowingly sell the personal information of minors under 16 years of age.
11. Changes to This Privacy Policy
We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If we do, then we will notify you here, as well as by posting a notice on our Site or by e-mailing you. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
12. Contact Information
If you have any questions or comments about this Privacy Policy, please contact us at support@FriendsFlashback.com.